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The sanctions record · General Division of the High Court of Singapore, 2026

Tan Hai Peng Micheal v Tan Cheong Joo

Tan Hai Peng Micheal and another (as the executors of the estate of Tan Thuan Teck, deceased) v Tan Cheong Joo and another and other matters [2026] SGHC 49 · Originating Claim Nos 381 of 2023, 382 of 2023 and 201 of 2024 · S Mohan J · 6 March 2026

Judgment read in full, eighty-four paragraphs; every quotation is from it. Source: the judgment as published by the Singapore courts on eLitigation.

Two solicitors, S$5,000 each, paid personally. Closing submissions for the defendants cited two authorities that do not exist, on the burden of proof, a central issue in the trial. The court found, as it had in its earlier judgment on the merits, that “there were reasonable grounds to suspect that the citations were likely to have been generated by an AI tool”, but after letter upon letter neither solicitor could confirm whether one had been used. It ordered personal costs of S$5,000 against Mr Goh, counsel on record, and S$5,000 against Mr Sidhu, the solicitor he engaged to help with the research and drafting, on an indemnity basis. The S$1,500 the solicitors had offered was “plainly inadequate”. Neither solicitor may pass any part of it to the clients, “whether directly or indirectly”. No disciplinary referral was made.

The record

  • CourtGeneral Division of the High Court of the Republic of Singapore
  • JudgeS Mohan J
  • CaseThree informally consolidated suits by the executors of the late Tan Thuan Teck to recover loans from four brothers and a family company. The claimants won on the merits in the earlier judgment, [2025] SGHC 217; this judgment decides costs and the fictitious authorities
  • Date6 March 2026
  • SanctionedMr Goh Peck San, counsel on record for the defendants; and Mr Amarjit Singh Sidhu, the solicitor Mr Goh engaged to assist with research and the drafting of the closing submissions
  • The errorTwo fictitious authorities at paragraphs 67 and 68 of the closing submissions, found by the claimants’ counsel. “Case A” paired a real neutral citation with the name of a different real case; “Case B” was invented in both name and citation. Neither supported the propositions it was cited for. The court did not repeat the citations, to prevent further dissemination of false information
  • ToolNot confirmed. Mr Sidhu said a paralegal, since departed and uncontactable, prepared the first draft, and that he had told staff not to use ChatGPT or any other AI tool. The court found it “plainly evident that such a tool was most likely employed”
  • AmountS$5,000 against Mr Goh and S$5,000 against Mr Sidhu, each personally, payable to the claimants, on an indemnity basis; S$10,000 in all, counted within the S$180,000 costs of the suits
  • ClientsNeither solicitor may charge the defendants for time spent on the issue, or pass on any part of the personal costs. Mr Goh must tell the defendants of the judgment and the orders, give them a copy, and confirm to the court within seven days that he has
  • DisciplineNo referral. The court warned that such conduct may, in an appropriate future case, lead to disciplinary action
  • EarlierTajudin bin Gulam Rasul v Suriaya bte Haja Mohideen [2025] 5 SLR 518, the first reported Singapore case on fictitious authorities cited by counsel, with a personal costs order of S$800

What the court found

The court began from the point that the tool is not the issue. Using AI is not objectionable in itself, it said, but “AI tools can only ever play the part of the handmaiden.”

“In view of this inescapable duty as officers of the court, it is immaterial whether the fictitious authorities were generated by an AI tool or by any other means.”

On counsel on record, the court looked at the signature. Who finalised the submissions was still not clear, so it assumed Mr Goh did, and held that his duty to see that they were complete, accurate and verified could not be delegated: “By appending his signature to the final version of the submissions that were filed and served, he thereby accepted personal responsibility for all material submitted to the court.” Neither case appeared in the bundle of authorities filed with the submissions, which a reasonably diligent solicitor would have treated as a red flag.

On the assisting solicitor, the court held that the power to order personal costs is not limited to counsel on record: “A personal costs order may be made against any solicitor responsible for the conduct in question.” Mr Sidhu had read the draft “about twice” and said he had “honestly overlooked” the two cases. The court answered that “a paralegal is not qualified to prepare written submissions independently”, and that supervision and verification were his.

Between the two of them, “the issue fell between two stools”. The court also recorded what it called a disconcerting feature of the case:

“despite multiple letters from the court, Mr Goh and Mr Sidhu remain unable to provide confirmation on whether the Fictitious Cases had been included in the closing submissions as a result of the use of an AI tool to prepare a draft of the submissions.”

That inclusion, without any inkling whether AI had been used, “indicates a lax system of control and supervision”. The court accepted that the conduct was not intentional and noted both solicitors’ apologies, but held that “the vice is not in the use of GenAI per se but the lawyer’s omission to verify the existence and accuracy of the authorities cited in the output generated by the GenAI tool utilised”.

The two solicitors asked to settle the matter privately, at S$1,500 between them, and Mr Sidhu offered to pay Mr Goh’s share. The court refused both. “It is in the interests of both the public and the legal profession that the matter not be dealt with privately.” And on the split: “Each solicitor bears a commensurate degree of fault.”

Why it matters

Three features travel. First, the order reached the solicitor who did the drafting, not only the one whose name was on the record. The court read its costs rule and its inherent power to cover any solicitor responsible for the conduct.

Second, the signature. Counsel on record could not shift the duty to the solicitor he engaged, and that solicitor could not shift it to a paralegal. Each was ordered to pay separately, and the court refused to let the matter be settled out of view.

Third, the clients. The cost may not reach them, directly or indirectly, and they must be told of the judgment and given a copy. The court pointed to the Singapore courts’ own guide on generative AI, which says that where a lawyer cites a fictitious AI-generated authority, “a personal costs order may be made against him”.

The lesson for the next filing

Two solicitors, a departed paralegal and several letters from the court, and still no one could say whether an AI tool had produced the two citations, or who had checked them. A record made at the time of filing, of what was checked and by whom, answers both questions.

Regulayer™ creates checkable evidence of who approved exact words and when: which AI was used, what a named person reviewed, and the document it was sealed to, made at the time and verifiable free by the court without trusting the person who made it. It does not do the checking. It shows that the checking happened, and who stood behind it.

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Sources

Related

Checked against the judgment, read in full. Information, not legal advice, and not advice on Singapore law.

Information, not legal advice. Every entry is verified against the court’s own document or contemporaneous reporting; where a source is reporting rather than the document, we say so.